Attachment A NRMLA Dirty Dozen Unethical Advertising Practices Attachment A to NRMLA Ethics Advisory Opinion 2012-1 The following are unethical advertising practices that have been expressly addressed by the NRMLA Ethics and Standards and Ethics Committee, though its Ethics Advisory Opinions and under the NRMLA Code of Ethics and Responsibility (the Code of Ethics). All NRMLA Members are required to and do subscribe to the Code of Ethics. Code of Ethics requirements apply to NRMLA Members directly, and NRMLA Members also are held accountable under the Code of Ethics for the indirect actions of the vendors (including advertising and lead generation providers) they engage. This list of the NRMLA Dirty Dozen of Unethical Advertising practices is illustrative of the requirements of the Code of Ethics in this area, and not exhaustive. Additional information about the Code of Ethics and its requirements, and the Committee’s Ethics Advisory Opinions, and this Dirty Dozen list, may be found at www.NRMLAOnline.org. The NRMLA Dirty Dozen Unethical Advertising Practices List: 1. Advertising HECM loan programs as a “Government Loan” or “Government Benefit,” or the lender’s loan as HUD or AARP “approved.” 2. Advertising that a failure of a senior to respond will or may result in the loss of a consumer benefit to which the consumer is entitled. 3. Advertising exaggerated or misleading benefits (such as “We (the lender) pay off your loan”), particularly without fairly describing related risks. 4. Advertising celebrity testimonials or endorsements without disclosing the paid nature of the arrangement. 5. Advertising a requirement that another product or service (such as an annuity) also must be purchased from the lender in order to obtain a reverse mortgage loan, particularly if such other product or service also does not provide a bona fide advantage to the consumer. 6. Advertising to a business partner unreasonably high compensation paid to it by the consumer through reverse mortgage loan proceeds, even if such compensation clearly and timely is disclosed to the consumer. 52
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